Bill Locum Tenens According to CMS Guidelines

Substitute physicians can contribute to a practice’s revenue stream when modifier Q6 is used properly.

By LuAnn Jenkins, CPC, CPMA, CMRS, CEMC, CFPC

Locum tenens is a Latin phrase that means “(one) holding a place.” In the medical field, locum tenens are contracted physicians who substitute for a physician who has left the practice, or who is temporarily unavailable (e.g., on medical leave, on vacation, etc.). The Centers for Medicare & Medicaid Services (CMS) allows payment for services provided by locum tenens physicians, but you’ll need to follow the guidelines closely.

Identifying Locum Tenens

The locum tenens physician does not have to be enrolled in the Medicare program or be in the same specialty as the physician for whom he or she is filling in, but the locum tenens must have a National Provider Identifier (NPI) and possess an unrestricted license in the state in which he or she is practicing.

A locum tenens physician cannot be used to cover expansion or growth in a practice. Medicare beneficiaries must seek to receive services from the regular physician, and services may not be provided by the locum tenens over a continuous period of more than 60 days (with the exception of a locum tenens filling in for a physician who is a member of the armed forces called to active duty).

Note: Check with the state’s Medicaid office and commercial carriers on their policies for locum tenens; some may follow CMS policy, but others may require enrollment.

Billing for Locum Tenens

Locum tenens physicians may not bill Medicare; they should be paid on a per diem or similar fee-for-time basis.

Claims payment is made under the name and billing number of the physician or the practice (in the event the physician has left the practice) that hired the locum tenens physician. If the physician has left the practice, every claim still must have a rendering provider, so the practice would still use his or her name and NPI with modifier Q6 Services furnished by a locum tenens physician appended to the procedure code to indicate the service was furnished by a locum tenens physician.

The practice must keep on file a record of each service furnished by the locum tenens physician, with his or her NPI or Unique Provider Identification Number (UPIN).

Do not bill for services provided by locum tenens while waiting for a physician to be credentialed with Medicare. (For more information on this, see Michael D. Miscoe’s, JD, CPC, CASCC, CUC, CCPC, CPCO, CHCC, article “Risks Abound for Non-credentialed Physicians Using Incident-to Rule” in the January 2014 issue of Healthcare Business Monthly.) If the physician is hired, the practice should submit the enrollment forms and wait for enrollment to be completed.

Avoid Common Misunderstandings

The locum tenens provision is widely used, but often misunderstood, which puts practices at risk if the guidelines are not followed. A big concern has been incorrect or misunderstood advice from companies placing locum tenens. Many are reputable companies that clearly understand CMS rules, but others may mislead offices to think they can keep locum tenens long term, or use nurse practitioners as locum tenens.

Section 1842(b) (6) (D) of the Social Security Act clarifies that this is a “physician for physician services” provision. In other words, services provided by non-physician practitioners (e.g., nurse practitioners and physician assistants) may not be billed under the locum tenens provision.

Ultimately, it is the responsibility of the physician or group practice to know and follow locum tenens guidelines.

LuAnn Jenkins, CPC, CPMA, CMRS, CEMC, CFPC, is the president of MedTrust, LLC, a practice management consulting and medical billing firm located in Michigan. She speaks on coding and reimbursement issues for the Michigan State Medical Society, is past president of the Michigan Medical Billers Association, and was named 2006 AAPC Coder of the Year. She is a member of the Grand Rapids, Mich., local chapter.

Renee Dustman, BS, AAPC MACRA Proficient, is an executive editor at AAPC. She holds a Bachelor of Science degree in Media Communications - Journalism. Renee has more than 20 years experience in print production and content management. Follow her on Twitter @dustman_aapc.

Renee Dustman, BS, AAPC MACRA Proficient, is an executive editor at AAPC. She holds a Bachelor of Science degree in Media Communications - Journalism. Renee has more than 20 years experience in print production and content management. Follow her on Twitter @dustman_aapc.

15 Responses to “Bill Locum Tenens According to CMS Guidelines”

It says that the locum can bill under the permanent provider for no more than 60 consecutive days. Does that mean that the locum can only bill under the other provider for basically 2 months, then needs to do his own billing paperwork? or would the locum be able to bill under the other doctor for 12 months if he did 5 days of coverage a month, which would equal 60 days of coverage?

Within this article there is a statement—Do not bill for services provided by locum tenens while waiting for a physician to be credentialed with Medicare. (For more information on this, see Michael D. Miscoe’s, JD, CPC, CASCC, CUC, CCPC, CPCO, CHCC, article “Risks Abound for Non-credentialed Physicians Using Incident-to Rule” in the January 2014 issue of Healthcare Business Monthly.) If the physician is hired, the practice should submit the enrollment forms and wait for enrollment to be completed—-
This article is around billing Locum Tenens so I’m curious how “Incident to” rules apply? My question is, can my family practice office use a Locum Tenens Physician who we know we are going to hire but is not credentialed yet. So they are not an employee at this time but we are working to get them credentialed. Once the credentialing is complete we would hire them on and their start date as an employee would begin after the credentialing is complete? So we wouldn’t be billing “incident to” we would be billing Locum Tenens for a non-employed Physician. Please help clarify, thank you.

I am curious to find out the answer to Angele Pommarane’s question. We are in the same boat however with a NP. She is not credentialed as of yet and with our Physician out of the office we are curious to know if we can use her as Locum Tenens, until credentialing process is complete and hire her on.

We are contracted with a clinic to provide coverage in our mental health unit. They want one of their physicians to take call next weekend that is not credentialed at our hospital. We will be working to get her temporary privileges. Are we able to bill for these services as a locum tenens under one of our full-time providers that is credentialed here? The payer credentialing will not be completed in this amount of time. They don’t have anyone else to provide the call we need. Thank you!

We have an instance where we are using a locum for a provider on extended vacation. Before the 60 days was up she gave her notice. The job was offered and accepted by the Locum with a start date 2 weeks after the 60 days Locum contract terminates. Can we start the credentialing while he is still a Locum?

Question: A physician practice that has 2 hospitals and 2 imaging centers. Can the credentialed/Owner of the Practice read at one of the facilities/hospital and have the Locum read at the other facility/hospital on the same date using the same tax ID different locations?

Regarding a locum tenens (fee for time), if a “fee for time” physician that is covering for another practice (or physician), what information can you give me if that physician who is rounding ends up doing a procedure? Does the rounding physician bill the procedure from his own practice? There would be a credentialing issue for the hospital and the physician. Could you shed some light on this or steer me in the right direction?

What if a locum is covering a provider and then the provider retires, how do we continue to bill and collect for the locum. My understanding the Q6 modifier is representing the locum covering for the provider but now the provider has retired and the provider rendering the service is still a locum and is going to remain a locum, what do you do in this case?

Our locum is here and the provider has left the practice. We understand 60 days and Q6 but what about the EHR documentation?
Does that go under both their names or just the locum? Or under the provider they are covering for?

I have two questions based on the information above. in the opening of your article, you basically stated, a locum tenens does not need to be credentialed with Medicare nor the same specialty as the physician for whom they are to provide substitution. They just need to have a NPI number and an unrestricted license in the state for which they are practicing. First, At the time this was written, not being of the same specialty may have been allowed, but since then CMS has stated for example, radiation therapy cases using Intensity Modulated Radiotherapy (IMRT) and Image Guided Radiotherapy (IGRT) the physician must have the appropriately training and expertise acquired within the freamework of an accredited residency and/or fellowship program in the specialty/subspecialty, i.e. Radiation Oncology (CMS Pub. 100-08, Ch 13, section 13.5.1). Therefore, i would like to know if your original information is still applicable by today’s standards?
Secondly, . i would also like to know,if a Resident or Fellowship student be used as a locum tenen prior to completion of said program(s)? Most information regarding locum tenens is pretty vague on this aspect. Thank you.

I have two questions based on the information above. in the opening of your article, you basically stated, a locum tenens does not need to be credentialed with Medicare nor the same specialty as the physician for whom they are to provide substitution. They just need to have a NPI number and an unrestricted license in the state for which they are practicing. First, At the time this was written, not being of the same specialty may have been allowed, but since then CMS has stated for example, radiation therapy cases using Intensity Modulated Radiotherapy (IMRT) and Image Guided Radiotherapy (IGRT) the physician must have the appropriately training and expertise acquired within the freamework of an accredited residency and/or fellowship program in the specialty/subspecialty, i.e. Radiation Oncology (CMS Pub. 100-08, Ch 13, section 13.5.1). Therefore, i would like to know if your original information is still applicable by today’s standards?